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“reasonable cause”

PenaltySection 273BSection 273B7,285 judgments

The decision most relied on for reasonable cause is Ashok Pai v. CIT (292 ITR 11), cited in 812 judgments on BharatTax.

Leading authorities on reasonable cause

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

Balakrishnan v. M. Krishnamurthy
7 SCC 123 · 1998 · Supreme Court
368
citing judgments

The Supreme Court outlines the principles for condoning delay in filing appeals, stating that a litigant's lapse is not always a bar if the explanation is bona fide and not a dilatory strategy. Courts should show utmost consideration to suitors and prioritize substantial justice unless the delay is deliberately to gain time.

Akhil Bhartiya Prathmik Shikshak Sangh Bhawan Trust v. ADIT
115 TTJ 419 · 2008 · ITAT
292
citing judgments

Penalty under Section 272A(1)(d) for non-compliance with a notice issued under Section 142(1) is not leviable when the assessee demonstrates a reasonable cause for such non-compliance. The decision defines what constitutes 'reasonable cause' in this context.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

CIT v. K.S.P. Shanmugavel Nadai and Ors.
153 ITR 596 · 1985 · High Court
171
citing judgments

Where a reasonable cause for delay in filing an appeal exists, the period of delay may not be a relevant factor for condonation. The court has condoned even substantial delays, such as nearly 21 years, based on the presence of a reasonable cause.

People Education and Economic Development Society (PEEDS) v. ITO
100 ITD 87 · 2006 · ITAT
121
citing judgments

When substantial justice and procedural technicalities are in conflict, especially in cases involving non-deliberate delay, the cause of substantial justice must be prioritized. The opposing party cannot claim a vested right to benefit from injustice due to such delays.

Commissioner of Income Tax v. Noida Toll Bridge Co. Ltd.
262 ITR 260 · 2003 · High Court
121
citing judgments

Journal entries for accepting or repaying loans and deposits, without any actual cash transaction, do not violate the provisions of Section 269SS or Section 269T of the Income Tax Act. Consequently, such transactions do not attract penalties under Section 271D or Section 271E.

Judgments citing reasonable cause

Rp Panchal HUF, Mumbai vs. Income Tax Officer, Ward-31(3)(2), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2452/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 250

that as it may, without going into the merits of the issues raised by the assessee and considering the fact that there was reasonable cause, because of which assessee could not put effective representation before Ld. CIT(A). Hence the Bench is of the view that one more opportunity

Nayan Builders and Developers Private Limited, Mumbai vs. ITO WD 7(2)(3), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2322/MUM/2025[2003-2004]Status: DisposedITAT Mumbai22 Sept 2025AY 2003-2004

Bench: Hon’Ble Shri Sandeep Gosain

Section 250

assessee and taking into consideration the facts narrated before us and while taking a lenient view that, I find that there was reasonable cause, because of Nayan Builders & Developers Pvt Ltd., Mumbai which assessee could not put effective representation before Ld. CIT(A). Hence the Bench is of the view

Nayan Builders and Developers Private Limited, Mumbai vs. ITO WD 7(2)(3), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2310/MUM/2025[2010-2011]Status: DisposedITAT Mumbai22 Sept 2025AY 2010-2011

Bench: Hon’Ble Shri Sandeep Gosain

Section 250

assessee and taking into consideration the facts narrated before us and while taking a lenient view that, I find that there was reasonable cause, because of Nayan Builders & Developers Pvt Ltd., Mumbai which assessee could not put effective representation before Ld. CIT(A). Hence the Bench is of the view

Shri Jigar Kishor Mehta, Mumbai vs. ITO Ward 41(4)(2), Mumbai

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

ITA 107/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Sept 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2013-14 Shri Jigar Kishor Mehta, The Ito-41(4)(2), 50/5, Dhanji Street, 1St Agairy Kautilya Bhavan, Bandra Kurla Lane, Masjid Bunder, Vs. Complex, Bandra (East), Mumbai-400 003. Mumbai-400051. Pan No. Afopm 9328 Q Appellant Respondent

For Appellant: Ms. Kavita Kaushik, Sr. DRFor Respondent: Mr. Abhishek Khandelwal, Adv
Section 2(22)(e)

respectfully submits that said delay has risen due to reasons beyond its control, inadvertently and due to beyond its control, inadvertently and due to reasonable cause. reasonable cause. I submit that the said matter was being monitored and being I submit that the said matter was being monitored and being

Jaya Nursing Home, Nalanda vs. ITO, Ward- 2 (3), Biharsharif

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 335/PAT/2025[2017-18]Status: DisposedITAT Patna19 Sept 2025AY 2017-18

Bench: The Learned Cit(A). However, The Appeal Was Dismissed Ex Parte On Account Of Non-Compliance On Various Dates, Thereby Sustaining The Order Of The Assessing Officer.

Section 144Section 250Section 69A

Ajay Kumar Choudhary, partner of Jaya Nursing Home. After considering the explanation offered, we are satisfied that the delay was due to reasonable cause, and hence the delay in filing the appeal is condoned. 9. In view of the above discussion, the appeal of the assessee is allowed for statistical

Rajhans Nagari Sahakari Patsanstha Maryadit, Mogalpura vs. ITO Ward 2, Ahmednagar

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1773/PUN/2025[2018-19]Status: DisposedITAT Pune19 Sept 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1773/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Rajhans Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S. Ward-2, Pune. 1, Mogalpura, Sangamner, Tal-Sangamner, Dist-Ahmednagar, Ahmednagar – 422605. Pan: Aaaar3555J Appellant/ Assessee Respondent / Revenue Assessee By Shri Piyush Bafna Revenue By Shri Aviyogi Ambadkar– Add.Cit(Dr) Date Of Hearing 10/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19, Dated 20.03.2025 Emanating From Assessment Order U/S.154 Of The I.T.Act, Dated 26.11.2019. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(1)Section 143(1)(a)Section 154Section 234ASection 234FSection 250Section 250(6)Section 80P

other grounds, the learned CIT(A) has erred in not condoning the delay in filing the appeal before him despite there being a reasonable cause explained during the course of appellate proceedings as well as by way of affidavit and hence the appeal of the Appellant may please be admitted

Musculoskeletal Society (Mss), Hyderabad vs. ITO., Exemption Ward-1(4), Hyderabad

In the result, the appeal of the assessee is allowed for statistical

ITA 1177/HYD/2025[2025-2026]Status: DisposedITAT Hyderabad19 Sept 2025AY 2025-2026
Section 12A

objected to the condonation of delay. It was argued that the reasons furnished by the assessee are not sufficient and do not constitute “reasonable cause” within the meaning of law. It was submitted that the delay ought not to be condoned and the appeal deserves dismissal on the ground

Labtop Instruments Private Limited, Vasai vs. Addl. CIT, 11(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4916/MUM/2025[2010-11]Status: DisposedITAT Mumbai19 Sept 2025AY 2010-11

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Ms. Vidhi SolaniFor Respondent: Shri Surendra Mohan, Sr.DR
Section 269SSection 271DSection 273B

fact that the loans were accepted in case from the Director, Shri Byju George in contravention of section 269SS of the Act and no reasonable cause has been shown under section 273B, penalty u/s.271D of the Act was levied. 4. The assessee, thereafter carried the matter in appeal before ... bank account for meeting the business exigencies and the penalty levied by the AO was set aside. It was accordingly submitted that there was reasonable cause for the assessee-company to accept the cash amount from its Director and, therefore, there is a reasonable cause in not complying with

Lic Mutual Fund Asset Management Limited, Mumbai vs. DCIT-1(2)(1), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 4246/MUM/2025[2022-23]Status: DisposedITAT Mumbai19 Sept 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2022-23 Lic Mutual Fund Asset Dcit-1(2)(1), Management Limited, Aayakar Bhavan, 4Th Floor, Industrial Assurance Vs. Maharshi Karve Road, Building, Mumbai-400020. Opp: Churchgate Station, Churchgate, Mumbai-400020. Pan : Aaacj1166H (Appellant) (Respondent) For Assessee : Shri Madhur Agrawal & Shri Ravikant Pathak For Revenue : Shri Rajesh Kumar Yadav, Cit-Dr Date Of Hearing : 15-09-2025 Date Of Pronouncement : 19-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Pr. Commissioner Of Income Tax, Mumbai-1, [„Ld.Pcit‟], Dated 07-03- 2025, U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Pertaining To Assessment Year (Ay) 2022-23, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “1.The Hon'Ble Principal Commissioner Of Income Tax, Mumbai-1 (Hereinafter Referred As Hon'Ble Pcit] Erred In Setting Aside The Assessment Order Passed U/S 143(3) Of The Income Tax Act, 1961 ("Act") & Passing The Revision Order U/S 263 Of The Act.

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 143(2)Section 143(3)Section 263

both the parties and perusing the affidavit placed on record the contents of which have remain unrebutted before us, we find that there was reasonable cause for the delay in filing the present appeal, the delay is hereby condoned and appeal is admitted for adjudication. 3. Briefly the facts

Pushpanjali Constructions Private Limited, Pushpanjali Palace, Dehli Gate, Agra vs. DCIT, Cen Cir Ghaziabad

In the result appeal filed by the assessee is partly allowed

ITA 1001/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Ms. Amisha S. Gupt, CITDR
Section 143(3)Section 153ASection 153CSection 153DSection 69C

condonation of delay, We have heard both the counsels on the issue of condonation of delay. In our considered opinion, there was a reasonable cause for the delay in filing the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal. Ground Nos.1

Ram Lakhan Dwivedi, Maihar vs. Income Tax Officer- Ward 1, Satna

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 180/JAB/2024[2019-20]Status: DisposedITAT Jabalpur18 Sept 2025AY 2019-20

Bench: Shri Kul Bharatassessment Year: 2019-20 Ram Lakhan Dwivedi V. Income Tax Officer 139, Rohaniya Khurd, Pakaria, Ward-1, Satna Distt-Maihar-485773. Income Tax Office, Civil Lines Chowk, Satna- 485001. Pan:Exmpd6359C (Appellant) (Respondent) Appellant By: Ms. Apoorva Garg, Ca Shri Kng Pillai, Advocate Respondent By: Shri N. M. Prasad , Sr. Dr-1 Date Of Hearing: 17 09 2025 Date Of Pronouncement: 18 09 2025 O R D E R

For Appellant: Ms. Apoorva Garg, CAFor Respondent: Shri N. M. Prasad , Sr. DR-1
Section 115BSection 144Section 147Section 148Section 234ASection 234BSection 271ASection 69A

assessee contended that the notices were not received by the assessee and even the assessment order was not received. Therefore, for the „reasonable cause‟, there was delay in filing of the appeal before the Ld. CIT(A). It was further contended that the investment were made out of explained sources ... Departmental Representative (DR) opposed the submissions and supported the orders of the lower authorities. He contended that the assessee did not prove the „reasonable cause‟ for delay in filing the appeal before the Ld. CIT(A). Therefore the Ld. CIT(A) was justified in dismissing the appeal of the assessee

Dhanya Kumar Jain, Jabalpur vs. ITO Ward 2(1), Jabalpur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 173/JAB/2024[2017-18]Status: DisposedITAT Jabalpur18 Sept 2025AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18 Dhanya Kumar Jain V. Ito Ward-2(1) 2719, Nagpur Road, Garha, Income Tax Office, Annexe Tripuri Chowk, Jabalpur- Building, Nagrath Chowk, 482001. Jabalpur-482001. Pan:Awdpj1526D (Appellant) (Respondent) Appellant By: Shri Rahul Bardia, Ca Respondent By: Shri Alok Bhura, Sr. Cit(Dr) Date Of Hearing: 17 09 2025 Date Of Pronouncement: 18 09 2025 O R D E R

For Appellant: Shri Rahul Bardia, CAFor Respondent: Shri Alok Bhura, Sr. CIT(DR)
Section 142(1)Section 143(2)

Counsel for the assessee reiterated the submission as made in the application seeking condonation. The delay in filing was not deliberate but due to reasonable cause he prayed for condonation of delay. The relevant contents of the application are reproduced as under:- “1.The present appeal is filed against ... submitted that the assessee has been negligence in filing of appeal. The assessee cannot take advantage of its negligence and there is no reasonable cause for not filing the appeal in time by the assessee. The condonation application deserves to be dismissed. 4. I have heard the rival submission

Triyugi Narayan Dwiwedi, Rewa vs. Income Tax Officer - Ward - 1, Rewa

In the result, the appeal of the assessee is allowed

ITA 137/JAB/2024[2016-17]Status: DisposedITAT Jabalpur18 Sept 2025AY 2016-17

Bench: Shri Kul Bharatassessment Year: 2016-17 Triyugi Narayan Dwivedi V. Income Tax Officer Ward No.03, Bramhan Tola Ward-1 Dhari Khadda, Semariya Distt- Kothi Compound Becides Rewa-486001. Family Court, Rewa- 486001. Pan: Bhbpd4469B (Appellant) (Respondent) Appellant By: Ms. Apoorva Garg, Ca Shri Kng Pillai, Advocate Respondent By: Shri N.M. Prasad, Sr.Dr-1 Date Of Hearing: 17 09 2025 Date Of Pronouncement: 18 09 2025 O R D E R

For Appellant: Ms. Apoorva Garg, CAFor Respondent: Shri N.M. Prasad, Sr.DR-1
Section 142(1)Section 144Section 147Section 250Section 251Section 271(1)(b)Section 56Section 69A

statutory notices under sec. 142(1) of the Act is unjustified and unwarranted, particularly when the non-compliance was on account of sufficient and reasonable cause and therefore, such penalty deserves to be cancelled. Page 2 of 4 4. The appellant craves leave to add, alter, modify any ground ... considered view that the assessee has successfully demonstrated that the non-compliance of the notices as issued was due to reasonable cause. Under these facts, the Assessing Officer ought not to have imposed the impugned penalty. Therefore, I hereby direct the Assessing Officer to delete the penalty. Grounds of appeal

Rajesh Kumar, Patna vs. ITO, Ward- 3 (2), Gaya

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 171/PAT/2025[2018-19]Status: DisposedITAT Patna18 Sept 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 147Section 234ASection 250Section 271FSection 69A

portal, I earnestly pray that the delay in filing of the appeal may kindly be condoned as I am prevented by sufficient and reasonable cause from not filing the appeal within the timeline from the date of order and/or its uploading of order on the e-portal

Kanishka F&B, Vijayawada vs. Income Tax Officer, Ward-2(2), Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated hereinabove

ITA 501/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam18 Sept 2025AY 2018-19

Bench: the Tribunal. In respect of the belated filing of the appeal, the assessee filed a petition for condonation of delay along with an affidavit and the relevant paragraphs from the affidavit are extracted herein below:

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

appeal beyond the prescribed time limit with a delay of 193 days, we are of the considered view that there is a sufficient and reasonable cause that prevented the assessee in 3 Kanishka F & B vs. ITO filing the appeal within the prescribed time limit. Therefore, we hereby condone

Mo. Shariph Kureshi, Sikar vs. ITO Ward-4 Sikar, Sikar

In the result, the appeal of the assessee is allowed

ITA 366/JPR/2025[2013-14]Status: DisposedITAT Jaipur18 Sept 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT
Section 144Section 147Section 148Section 234ASection 271(1)(c)

filing the appeal in time and we are satisfied that the delay in filing the appeal is 3 Mo. Shariph Kureshi, Sikar. due to reasonable cause. Thus, the delay of 7 days in filing the appeal by the assessee is condoned in view of the decision of Hon'ble Supreme

Indrajit Ramchandra Jagtap, Maharashtra vs. ITO TDS Ward Kolhapur

In the result, appeal of the assessee is allowed for statistical purposes

ITA 570/PUN/2025[2022-23]Status: DisposedITAT Pune18 Sept 2025AY 2022-23

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Harish Bist
Section 194Section 201Section 201(1)Section 250

email id and contact detail on ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause. Impugned order is hereby set aside and effective grounds of appeal raised by the assessee are allowed for statistical purposes. 9. In the result

Machindra Baburao Suke, Pune vs. ITO Ward 5(3), Pune

In the result, the appeal filed by the assessee is allowed as per the observations made in the order

ITA 1245/PUN/2025[2017-18]Status: DisposedITAT Pune18 Sept 2025AY 2017-18

Bench: Dr.Manish Borad

For Respondent: Appellant by Shri Amit Kumar
Section 143(2)Section 143(3)Section 250Section 68Section 69Section 69A

appeal. 3. After hearing both the sides and perusing the averments made in the condonation application, I am satisfied that there was ‘reasonable cause’ which prevented the assessee to file the appeal within the stipulated time. I note that the 2 Machindra Baburao Suke assessee would not have gained from

M/S. Rsv Skin & Laser Centre, Chennai vs. ACIT, Central Cricle 1(4), Chennai

In the result, all the appeals filed by the assessee(s) are allowed

ITA 1726/CHNY/2025[2018-19]Status: DisposedITAT Chennai18 Sept 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.B. Ramakrishnan, FCA &For Respondent: Ms. Gauthami Manivasagam
Section 132Section 142(1)Section 143(2)Section 153ASection 153CSection 271(1)(b)Section 272A(1)(d)

good faith and therefore, the omission to appear/respond to notice on 09.12.2019, can’t invite penalty. The assessee’s case are that they had reasonable cause for not complying with the notice dated 09.12.2019 and hence, assessee’s shouldn’t be fastened with penalty. Therefore, the Ld.AR prayed that penalty ... warranted in these cases u/s.271(1)(b) of the Act as well as u/s.272A(1)(d) of the Act since there was reasonable cause for the omission to comply with the directions given by the AO in his notice u/s.142(1) of the Act dated ITA Nos.1711 to 1714/Chny/2025

M/S. Rsv Skin & Laser Centre, Chennai vs. ACIT, Central Cricle 1(4), Chennai

In the result, all the appeals filed by the assessee(s) are allowed

ITA 1725/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Sept 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.B. Ramakrishnan, FCA &For Respondent: Ms. Gauthami Manivasagam
Section 132Section 142(1)Section 143(2)Section 153ASection 153CSection 271(1)(b)Section 272A(1)(d)

good faith and therefore, the omission to appear/respond to notice on 09.12.2019, can’t invite penalty. The assessee’s case are that they had reasonable cause for not complying with the notice dated 09.12.2019 and hence, assessee’s shouldn’t be fastened with penalty. Therefore, the Ld.AR prayed that penalty ... warranted in these cases u/s.271(1)(b) of the Act as well as u/s.272A(1)(d) of the Act since there was reasonable cause for the omission to comply with the directions given by the AO in his notice u/s.142(1) of the Act dated ITA Nos.1711 to 1714/Chny/2025